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1. Transfer pricing adjustments, selection of the most appropriate method (MAM), benchmarking approach (aggregation or segregation), factual rendering of services, arm's...

2. The case pertains to the levy of penalty u/s 271G for failure to furnish documents and information u/ss 92CA/92D. The key points are: The Transfer Pricing Officer (TPO)...

3. Transfer Pricing Adjustment - adjustment against AMP expenditure - Bright Line Test (BLT) - BLT method as adopted by Ld. TPO was not a valid method to benchmark the...

4. Transfer Pricing Adjustment - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied...

5. TP Adjustment - ALP is determined by TPO by not applying any method at all or by choosing a method which is not prescribed u/s.92C(1) of the Act, then such a...

6. Transfer pricing adjustment on management charges paid to associated enterprise was unreasonable. The assessee provided sufficient evidence of services rendered through...

7. The case involves Transfer Pricing (TP) adjustments and the classification of segments for benchmarking purposes. The Appellate Tribunal held that TP adjustments should...

8. TP Adjustment - the TPO is erred in adopting CUP method for few transactions when he has accepted overwhelming majority of transactions under TNMM method. The DRP...

9. Transfer Pricing Adjustments - downward adjustment made by the TPO and enhanced by the CIT(A) - adoption of the Transactional Net Margin Method (TNMM) over other methods...

10. TP adjustment - ALP determination - Selection or change in Most Appropriate Method (MAM) - “Other Method" v/s "CUP Method" - Assessee can resile from the most...

11. Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

12. The High Court held that a change in the approach of assessing tax, without any statutory change, leads to uncertainty in cash flow and fund flow, which are crucial for...

13. The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional...

14. Transfer pricing adjustment - the unusual features which remained unexplained by the assessee, influenced the TPO and the AO to resort to transfer pricing adjustment and...

15. TP Adjustment - re-computation of ALP by combining both Import of material and Export of Finished goods and applying TNMM and thereby upward adjustment - The order of...